INTRODUCTION

This is a quick reference guide for food businesses. It complements the main guidance on Food Traceability, Withdrawals and Recalls within the UK Food Industry, which has been produced to explain the legal requirements in relation to food traceability, withdrawals and recalls. The guidance can be found at:

Food Standards Agency

and

Food Standards Scotland

FOOD BUSINESSES’ RESPONSIBILITIES

As a Food Business Operator (FBO), you are responsible for the safety of the food which you produce, distribute, store or sell. You must:

- Not place unsafe food on the market (food is unsafe if it is injurious to health or unfit for human consumption)
- Comply with food law in the production, distribution, storage and sale of food
- Be able to trace suppliers of your food and the business customers that you have supplied
- Remove unsafe food from the market in the event of a food safety incident TRACEABILITY

Traceability helps keep track of food in the supply chain, which supports the accurate withdrawal/recall of unsafe food, if required. The more information you keep, the easier and quicker it will be to identify the affected food, mitigate risks to consumers and save time and money.

WHAT THE LAW SAYS

You must have **traceability information** for your suppliers and business customers (one step back and one step forward)

Retailers, including caterers, are not required to keep traceability information where they sell to the final consumer. However, where they supply food businesses, **all traceability requirements** must be adhered to

You must have systems and procedures in place to allow for traceability information to be made **available** to enforcement authorities **on demand**

You must **label** or **identify** food placed on the market to facilitate its traceability

Products of animal origin and sprouted seeds are subject to **specific** traceability requirements. KEY STEPS IN DEVELOPING A FOOD TRACEABILITY SYSTEM

1. THE SYSTEM You must be able to trace food/ingredients purchased from suppliers and then supplied to business customers (excluding food supplied to final consumer).

2. DEFINING BATCHES OF FOOD This will help to ensure good traceability and can limit the amount of food to be withdrawn/recalled.

3. TRACEABILITY INFORMATION

- Business name
- Business address
- Description of foods purchased and sold
- Quantities
- Transaction dates

4. RECORD KEEPING You must ensure your traceability information can be made available on demand.

HAVE YOU ALSO THOUGHT ABOUT...?

- Trading with suppliers who have good traceability systems in place
- Internal process traceability to enable you to match up inputs and outputs and ensure better visibility throughout your supply chain
- Length of time to keep traceability information
- Periodically reviewing the traceability system

For more information please refer to the TRACEABILITY section of the main guidance. FOOD WITHDRAWALS/RECALLS

If a food safety incident happens and the food has been supplied, it will have to be ‘withdrawn’ and if necessary ‘recalled’.

A withdrawal is the process by which unsafe food is removed from the supply chain, where unsafe food has not yet reached the consumer.

A recall is the process by which unsafe food is removed from the supply chain and consumers are advised to take appropriate action, for example to return or dispose of the unsafe food.

WHAT THE LAW SAYS

If you believe a food that you have imported, produced, processed, manufactured or distributed is unsafe you should immediately withdraw and/or recall the food where it has left the immediate control of your business.

You must inform enforcement authorities, FSA/FSS, suppliers (if relevant), business customers and consumers (consumers only when a recall is necessary) of the food safety incident and necessary actions. MAKING A DECISION TO WITHDRAW OR RECALL FOOD

In the event of a food incident, where the food has left your immediate control, you will need to determine if the food is unsafe and a course of action. The decision tree below outlines the process to follow.

In some cases, you may be able to easily identify that a food is unsafe. However, not all hazards that might be found in food are specified in food safety regulations and therefore you may be required to carry out a risk assessment.

For more information on the decision-making process and carrying out risk assessments please refer to the MAKING A DECISION TO WITHDRAW OR RECALL FOOD section of the main guidance. INITIATING AND MANAGING A FOOD WITHDRAWAL/RECALL

A number of key aspects need to be considered when initiating and managing a food withdrawal/recall:

**INFORMATION GATHERING/INVESTIGATION**

- Know the details of the problem
- Know which product and which batches are affected
- Carry out risk assessment (if necessary)
- Stop supply
- Ensure product is withdrawn and, if necessary recalled

**NOTIFICATION**

- Inform enforcement authorities, FSA/FSS, suppliers, business customers and consumers (if a recall is required)

**MONITORING PROGRESS**

- Throughout the food safety incident maintain communication with all relevant parties

**HANDLING UNSAFE FOOD**

- Label affected food clearly to show it should not be sold
- Make unsafe food safe if a product can be re-worked or re-labelled
- Dispose of unsafe food as waste

**KEY DECISION LOG TEMPLATE:** Downloadable through link below

**NOTIFICATION TEMPLATES:**

1. Enforcement Authority
2. Business to Business
3. Allergy Alert Point of Sale Notice
4. Food Recall Alert Point of Sale Notice All downloadable through link below

**WITHDRAWALS AND RECALLS GUIDANCE**

**BEST PRACTICE**

HAVE YOU ALSO THOUGHT ABOUT...?

- Notifying consumer, allergy and patient support organisations
- Monitoring progress of and closing a withdrawal/recall
- Reviewing the effectiveness of the withdrawal/recall and carrying out root cause analysis

For more information please refer to the INITIATING AND MANAGING A FOOD WITHDRAWAL/RECALL section of the main guidance.

## ROLES AND RESPONSIBILITIES

| Action | FBO initiating withdrawal/recall | Non-retail FBO receiving notification | Retailer receiving notification (inc caterers selling prepacked food) | Caterers receiving notification | |------------------------------------------------------------------------|----------------------------------|---------------------------------------|---------------------------------------------------------------------|---------------------------------| | Stop supply | ✓ | | | | | Notify relevant parties (enforcement authority, FSA/FSS, customers) | ✓ | | | | | Arrange for return/disposal of food | ✓ | | | | | Identify/label unsafe food and dispose of or re-work | ✓ | | | | | Remove unsafe food from supply chain/sale/service | ✓ | ✓ | ✓ | ✓ | | Advise business customers on actions to take | ✓ | ✓ | | | | Return unsafe food to FBO / dispose | ✓ | ✓ | ✓ | ✓ | | Prepare and issue/send POS notification RECALL ONLY | ✓ | ✓ | | | | Inform consumers of recall / retrieve unsafe food RECALL ONLY | | | ✓ | | | Accept return of affected food from consumers RECALL ONLY | | | | ✓ |

**BEST PRACTICE**

For more information please refer to the **ROLES AND RESPONSIBILITIES OF THOSE INVOLVED IN A WITHDRAWAL/RECALL** section of the main guidance.

**HAVE YOU ALSO THOUGHT ABOUT...?**

- Preparing additional communications material e.g. Q&A for consumers
- Checking that business customers are taking appropriate action USEFUL CONTACTS

To stay up to date with information on food recalls/allergy alerts please see:

For England, Wales and Northern Ireland

For Scotland

FSA Incidents Response Teams England Tel: 020 7276 8448 Email: foodincidents@food.gov.uk

Wales Tel: 02920 678961 Email: wales.foodincidents@food.gov.uk

Northern Ireland Tel: 02890 417700 Email: incidents.ni@food.gov.uk

Online Notification

FSS Scotland Scottish Food Crime and Incidents Unit Tel: 01224 285138 Email: incidents@fss.scot

Online Notification